Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
ITAT held that no undisclosed income can be computed based on uncorroborated loose slips seized from a third party's premises. The Tribunal found insufficient evidence to substantiate cash payment allegations, as the seized documents lacked specific details about the assessee, transaction amounts, or dates. No corroborative evidence was presented to confirm the presumed loan transactions. Consequently, the Assessing Officer's additions were deleted, and the ground of appeal was allowed. Additionally, the Tribunal permitted interest-free advances to a sister concern, recognizing the commercial rationale of avoiding potential external borrowing costs.
ITAT held that no undisclosed income can be computed based on uncorroborated loose slips seized from a third party's premises. The Tribunal found insufficient evidence to substantiate cash payment allegations, as the seized documents lacked specific details about the assessee, transaction amounts, or dates. No corroborative evidence was presented to confirm the presumed loan transactions. Consequently, the Assessing Officer's additions were deleted, and the ground of appeal was allowed. Additionally, the Tribunal permitted interest-free advances to a sister concern, recognizing the commercial rationale of avoiding potential external borrowing costs.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
